https://www.taxtmi.com/caselaws?id=38786 Amounts transferred to the contingencies reserve and development reserve under the Sixth Schedule to the Electricity (Supply) Act, 1948 were not deductible in computing taxable profits because the statutory appropriation did not divest the assessee of ownership. The contingencies reserve remained subject only to restrictions on use and investment, and the development reserve likewise continued to belong to the assessee, being earmarked for investment in the electricity supply business. The statutory limits did not amount to diversion of income by overriding title, nor did they convert the transfers into expenditure or loss. The consumer's benefit reserve principle was inapplicable because these reserves did not cease to form part of the assessee's real profits. en-us Tue, 14 Dec 1976 00:00:00 +0530 Fri, 17 Mar 2017 17:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=38786 Amounts transferred to the contingencies reserve and development reserve under the Sixth Schedule to the Electricity (Supply) Act, 1948 were not deductible in computing taxable profits because the statutory appropriation did not divest the assessee of ownership. The contingencies reserve remained subject only to restrictions on use and investment, and the development reserve likewise continued to belong to the assessee, being earmarked for investment in the electricity supply business. The statutory limits did not amount to diversion of income by overriding title, nor did they convert the transfers into expenditure or loss. The consumer's benefit reserve principle was inapplicable because these reserves did not cease to form part of the assessee's real profits. Case-Laws Income Tax Tue, 14 Dec 1976 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=38786